Ellen Brody Secures Summary‑Judgment Win in Karp v. United States

Roberts & Holland LLP congratulates Partner Ellen Brody, who secured a victory in the United States Court of Federal Claims, which granted a summary judgment in favor of our clients, the Karps, in their 2016 tax refund case.

The dispute concerned the validity of the taxpayers’ Form 4868 request for an automatic six-month extension to file their 2016 federal income tax return. The government argued that the extension was invalid because the taxpayers allegedly failed to make a reasonable estimate of their tax liability, resulting in an untimely filed refund claim.

The court rejected that position. In its opinion, the court concluded that the Karps did make a reasonable estimate when submitting their extension request and were therefore entitled to rely on the automatic extension. With the filing deemed timely, the court held that the taxpayers are entitled to a refund of their overpayment for the 2016 tax year.

This ruling reinforces key principles governing the extension process and provides clarity for taxpayers in this area.

Roberts & Holland is committed to representing clients in complex tax disputes before the IRS and in the federal courts.